Modern Slavery and Human Trafficking Statement

Sulis Hospital Bath Ltd

1. Introduction

Sulis Hospital Bath Ltd is a subsidiary of ROYAL UNITED HOSPITALS BATH NHS FOUNDATION TRUST/

(“Sulis Hospital Bath”) operating hospitals and providing clinical services to NHS-funded, self-paying and privately insured patients.

Sulis Hospital Bath is committed to preventing acts of modern slavery and human trafficking within its business and supply chain, and requires that its suppliers are similarly committed. To this end, we undertake the following steps to ensure we comply with relevant UK legislation and to mitigate the risk of modern slavery and human trafficking occurring in our supply chain, including:

• conducting due diligence process of all our existing suppliers;
• complying with our Modern Slavery Policy (“MSP”) when setting out our audit, monitoring, and reporting processes; and
• incorporating the key elements of our MSP into contractual approach to engaging new suppliers.

2. Policies

As part of our commitment to combating modern slavery, we have adopted an MSP and a Whistleblowing Policy. As we work with a range of suppliers to provide high quality healthcare services to our patients, we also seek to ensure our suppliers are aware of our MSP and adhere to the same high standards that we do.

3. Due diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, Sulis Hospital has a documented process for approving third-party suppliers. Sulis Hospital requires suppliers to complete a questionnaire confirming their compliance with quality, environmental aspects, health and safety, information security, equal opportunities, recruitment standards, and other relevant aspects. A full supplier review process is completed before appointment or on contract renewal, and adhoc reviews are undertaken if any concerns arise. Our Modern Slavery Questionnaire forms an additional part of the overall review process and, where it flags up any concerns, we investigate further before we decide whether to engage that supplier. We maintain an Approved Supplier Register that records all vetted third-party suppliers to the business.

Our procedures are designed to:

• establish and assess areas of potential risk in our business and supply chains;
• monitor potential risk areas in our business and supply chains;
• reduce the risk of slavery and human trafficking occurring in our business and supply chains; and provide adequate protection for whistle-blowers.

4. Risk and compliance

Sulis Hospital regularly evaluates the nature and extent of its exposure to the risk of modern slavery occurring in its supply chain by annual reviews of existing and new business areas and any affected policies.

Overall, we consider the healthcare sector to be low risk for acts of slavery and human trafficking, apart from single-use surgical instruments, uniform suppliers and outsourced support functions, which are medium risk areas. All current suppliers have been thoroughly assessed at the commencement of their contracts.

We will continue to ensure all our suppliers adhere to our MSP. We enforce a strict code of compliance and do not tolerate slavery and human trafficking within our supply chains. Where warranted, we will exercise our right to terminate our relationship with the supplier if we become aware that it has failed to comply with modern slavery legislation.

5. Effectiveness and KPIs

Sulis Hosptial uses key performance indicators (KPIs) annually to measure how successful we have been in ensuring that slavery and human trafficking are not taking place in any part of our business or supply chains. These are as follows for 2019:

• number of known incidents of slavery and human trafficking linked to Sulis Hospital either by its operations,
• business relationships or supply chain (currently nil);
• percentage and number of suppliers investigated on suspicion of human trafficking and slavery (nil);
• percentage and number of suppliers signed up to Sulis Hospital MSP requirements (100%/269); and
• percentage of procurement and HR staff trained on the issue of human trafficking and slavery and the application of our MSP (100%).

6. Training

Our employees are required to act in line with our policies (including MSP) that promote integrity and respect for each other. Our Sulis Hospital ethos stresses that “everyone matters”, irrespective of their job or background. Further training is provided to procurement and HR teams. It covers modern slavery and human trafficking and includes information on where the risks lie and how to minimise and prevent them.

Employees are taught the benefits of stringent measures to tackle slavery and human trafficking, as well as the consequences of failing to eradicate slavery and human trafficking from our business and supply chains.

7. Further actions and sign-off

Following our review of our actions this financial year to prevent slavery or human trafficking from occurring in our business or supply chains, we intend to continue reviewing KPIs annually and monitoring the robustness of the systems and controls we have in place.

This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes Sulis Hospital’s slavery and human trafficking statement for the financial year commencing 1 January 2019 and ending 31 December 2019.